SecProbe.io

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<TYPE>CORRESP
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<FILENAME>correspa_13021.txt
<DESCRIPTION>CORRESPONDENCE DATED OCTOBER 29, 2004
<TEXT>

                        [LETTERHEAD FOR ROPES & GRAY LLP]

October 29, 2004                                          Brian D. McCabe
                                                          (617) 951-7801
                                                          bmccabe@ropesgray.com

VIA FACSIMILE AND EDGAR (WITHOUT ENCLOSURES)
--------------------------------------------

U.S. Securities and Exchange Commission
Division of Investment Management
450 Fifth Street, N.W.
Washington, D.C. 20549
Attn.:  Dominic Minore

Re: MassMutual Premier Funds (formerly, The DLB Fund Group) (File No. 811-08690)
    ----------------------------------------------------------------------------

Dear Mr. Minore:

            This letter responds to comments you provided telephonically to
Russell G. Aborn regarding the Registration Statement on Form N-1A filed by The
DLB Fund Group (now named "MassMutual Premier Funds") (the "Trust") on August
13, 2004 (the "Registration Statement"). For convenience of reference, this
letter summarizes the comments before each of the Trust's responses. The
applicable pages from the Registration Statement are enclosed. I have indicated
on the applicable pages where the changes can be found by placing the number of
the comment at the top of each page.

1.  COMMENT:

Please explain supplementally the basis for choosing which class of shares the
existing shareholders of the Trust will receive when the Trust converts to a
multi-class structure.

RESPONSE:

Existing shareholders of the Trust will receive the class of shares whose
expected expense ratio is closest to the expense ratio borne by such
shareholders prior to the conversion to a multi-class structure.

2.  COMMENT:

Please confirm supplementally that the level of 12b-1 fees to be applicable to
existing shareholders of the Trust when the Trust converts to a multi-class
structure will not be higher than the current level of 12b-1 fees applicable to
existing shareholders of the Trust.

<PAGE>

RESPONSE:

The level of 12b-1 fees to be applicable to existing shareholders of the Trust
when the Trust converts to a multi-class structure will not be higher than the
12b-1 fees payable under the existing Rule 12b-1 plan previously approved by
shareholders of the Trust.

3.  COMMENT:

Please confirm supplementally that existing shareholders of the Trust will not
be subject to a deferred sales charge when the Trust converts to a multi-class
structure.

RESPONSE:

Existing shareholders of the Trust will not be subject to a deferred sales
charge when the Trust converts to a multi-class structure.

4.  COMMENT:

Please remove derivatives risk and leveraging risk from the Money Market Fund's
disclosure.

RESPONSE:

Derivatives risk and leveraging risk have been removed from the Money Market
Fund's disclosure.

5.  COMMENT:

Please confirm supplementally that the Money Market Fund will not invest in
inverse-floaters.

RESPONSE:

The Money Market Fund will not invest in inverse-floaters.

6.  COMMENT:

Please consider expanding the principal risks disclosure for each fund instead
of summarizing them later in the section titled "Summary of Principal Risks."

RESPONSE:

The Trust believes that its current disclosure with respect to risk factors is
organized "into readable and comprehensive segments and is consistent with the
intent of the prospectus to provide clear and concise information about the
Funds," thereby meeting the standard for organization of information in a
multi-fund prospectus set forth in General Instruction C.3.(c) of

                                        2
<PAGE>

Form N-1A. In addition, the Trust believes repetition of the "Summary of
Principal Risks" section after each series' investment objective and strategy
would conflict with Rule 421 under the Securities Act of 1933, as amended, as it
would increase "the size of the document but [would] not enhance the quality of
the information."

7.  COMMENT:

In the disclosure regarding the Inflation-Protected Bond Fund, if the average
credit quality standard that the fund will maintain is a weighted-average credit
quality standard, please revise the disclosure accordingly.

RESPONSE:

The requested change has been made.

8.  COMMENT:

For each fund, in the "Expense Information" section, please include the amount
of expenses to be reimbursed pursuant to the fee cap disclosed in footnotes
thereto, if not already included.

RESPONSE:

The requested change has been made.

9.  COMMENT:

With respect to the presentation of prior composite performance shown in the
disclosure regarding the Inflation-Protected Bond Fund, please make the
following changes:

     a.   Indicate that the prior performance shown is for all similar accounts
          managed by Babson;

     b.   Include disclosure to indicate that the similar accounts have similar
          policies and strategies, in addition to similar investment objectives;

     c.   Move the third sentence of footnote 1 to immediately under the heading
          "Babson Prior Performance for Similar Accounts";

     d.   In the first sentence of footnote 1, please change "significant" to
          "material"; and

     e.   Add "listed in the fee table above, including sales loads" to the end
          of the first sentence of footnote 1.

                                        3
<PAGE>

RESPONSE:

The requested changes have been made.

10.  COMMENT:

Confirm supplementally that the expenses for each class of the
Inflation-Protected Bond Fund are equal to or higher than the expenses charged
to the accounts that make up the composite of similar accounts.

RESPONSE:

The expenses for Classes Y, L, A and N of the Fund are equal to or higher than
the expenses charged to the accounts that make up the composite of similar
accounts. For Class S, the composite performance shown will not be adjusted to
reflect Class S expenses.

11.  COMMENT:

Confirm supplementally the method used to calculate the disclosed prior
performance for similar accounts.

RESPONSE:

The composite prior performance that is shown was calculated according to
Association of Investment Management and Research (AIMR) guidelines.

12.  COMMENT:

Where applicable, in the footnotes to each fund's performance information,
please indicate the significance of the dates prior to which performance
information provided is based on the performance of another class of shares.

RESPONSE:

The requested change has been made.

13.  COMMENT:

Please confirm supplementally that, where applicable for each fund, the
adjustment of performance information to reflect class-specific expenses does
not result in higher performance information than if such adjustment was not
made.

RESPONSE:

The adjustment of performance information to reflect class-specific expenses
does not result in higher performance information than if such adjustment was
not made.

                                        4
<PAGE>

14.  COMMENT:

Please confirm supplementally that, where applicable for each fund, the
adjustment of performance information to reflect class-specific expenses for
periods prior to the class inception date does not take into account the effect
of a fee waiver or cap.

RESPONSE:

The adjustment of performance information to reflect class-specific expenses
does not take into account the effect of a fee waiver or cap for periods prior
to the class inception date.

15.  COMMENT:

In the "Summary of Risk Factors" section, please include a chart to show
concisely which risk factors apply to each fund.

RESPONSE:

The requested change has been made.

16.  COMMENT:

In the second sentence of the second paragraph on page 64, please indicate that
the accounts were not subject to the restrictions of the Internal Revenue Code
of 1986, as amended, in addition to the restrictions of the Investment Company
Act of 1940, as amended.

RESPONSE:

The requested change has been made.

17.  COMMENT:

Please consolidate the disclosure in the third and fourth paragraphs on page 64
with the disclosure provided with respect to the presentation of similar account
performance information provided with the Inflation-Protected Bond Fund's
disclosure.

RESPONSE:

The requested change has been made.

18.  COMMENT:

Please include disclosure consistent with the last two sentences of "Other
Investment Companies" in the "Exchange Traded Funds" section of the SAI.

                                        5
<PAGE>

RESPONSE:

The requested change has been made.

19.  COMMENT:

Please remove clause two from the last sentence in each of the two fundamental
investment restrictions sections in the SAI.

RESPONSE:

The requested changes have been made.

20.  COMMENT:

Confirm supplementally that the expenses in the fee tables in the prospectus are
not shown net of the effect of the brokerage allocation arrangements disclosed
on page B-37 of the SAI.

RESPONSE:

The expenses in the fee tables in the prospectus are not shown net of the effect
of the brokerage allocation arrangements disclosed on page B-37 of the SAI.

21.  COMMENT:

In the first full paragraph on page B-37 of the SAI, please disclose the effect
of the disclosed brokerage allocation arrangements on the funds' brokerage
costs.

RESPONSE:

The requested change has been made.

                                  ------------

As requested, we acknowledge the following: (i) the Trust is responsible for the
adequacy and accuracy of the disclosure in the filing; (ii) SEC staff comments
or changes to disclosure in response to such comments in the filings reviewed by
the SEC staff do not foreclose the SEC from taking any action with respect to
the filing; and (iii) the Trust may not assert SEC staff comments as defense in
any proceeding initiated by the SEC or any person under the federal securities
laws of the United States. As indicated in the SEC's June 24, 2004 release
regarding the public release of comment letters and responses, you are
requesting such acknowledgements from all companies whose filings are being
reviewed and this request and these acknowledgements should not be construed as
suggesting that there is an inquiry or investigation or other matter involving
the Trust.

                                        6
<PAGE>

I believe that this letter addresses your comments. If you have any further
questions, please do not hesitate to call me at (617) 951-7801 or Russell G.
Aborn at (617) 951-7009. Thank you for your assistance.

Respectfully submitted,

/s/ Brian D. McCabe

Brian D. McCabe

Enclosures

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